According to the SEC: "Defendant engaged in acts and practices that created and/or maintained inappropriate influence by investment banking over research analysts, thereby creating conflicts of interest for its research analysts. Defendant failed to manage these conflicts in an adequate manner. During the relevant period, Defendant encouraged its research analysts to participate in investment banking activities, and used this participation as a factor to evaluate analysts and determine their compensation. The Research Department of Defendant coordinated the decision to initiate and maintain research coverage on certain companies with Defendant's Investment Banking Department, and coverage decisions were influenced by investment banking interests."

On March 19, 2010, the SEC published a litigation release announcing that the Honorable William H. Pauley issued an order approving modifications to the final judgments entered against J.P. Morgan Securities Inc. and the other firms covered by the Global Research Analyst Settlement.

The SEC consented to modifications to October 2003 and September 2004 final judgments against J.P Morgan and other investment banks covered by a global settlement of SEC And other enforcement actions against twelve investment banks and two individuals. In 2025, the settling firms filed motions to terminate their remaining undertakings under this settlement and the SEC consented.

Defendants filed an unopposed motion to modify final judgments. The SEC consented to the relief sought, agreeing that the final judgments should be modified. The SEC noted that "unique facts and circumstances" meant modification of the Judgment was in the public interest.